Sara 313 Reporting: the IMPACT of Changing Emission Estimates

摘要

Ever since the first reporting year, 1987, NCASI has been asisting its member ocmpanies in filing out from Rs by issuig annual updates to its Handbook for SARA section 313 Form R Reporting. OVer the years, pulp and paper mills have relied heavily on the use of industry-wide average estimates provided in this Handbook. The task of generating mill-specific estimates for most chemicals is generally quite cumbersome. Unfortunately, however, these estimates change from year to year. There are several reasons for these changes, mostly related to periodic genration of new data and to clarified or uncertain interpretations by both EPA and the regulated comunity of the reporting requiremnets. Thus, trends in annual releases reported by both EPA and the regulated community of the reporting requirements. Thus, trends in annual releases reported by a particular mill may have little to do with any real changes in process or production-related activities and more to do with the use of changing average estimates published in the Handbook. Using three model mills, one unbleached kraft and two bleached kraft, the predicted trends in air, water and land releases of several 313 chemicals are plotted for the period between 1987 and 1996, assuming the example mills strictly use the estimates provided in the Handbook. For comparison purposes, actual average releases reported in EPA's TRI database fro chemical pulp mills are also plotted for several of these chemicals. The results of this exercise show that in spite of no changes occurring within the model mills, theoretical annual reported releases go through significant fluctuations. Indeed, quite often, industry-wide average releases underscoring the role played by these estimates, as well as by modfied or clarified EPA interpretations on the reporting requirements for some chemicals.